Justia Civil Rights Opinion Summaries

The Supreme Judicial Court took this opportunity to augment the framework set forth in Duracraft v. Holmes Products Corp., 427 Mass. 156 (1998), regarding anti-SLAPP suits. Plaintiffs, nine registered nurses who previously worked in a hospital's adolescent psychiatric unit, fired the hospital and its then-president, alleging defamation based on the president’s statements - both to hospital employees and to the Boston Globe - regarding the nurses’ culpability for the incidents that took place at the unit. Defendants filed a special motion to dismiss pursuant to the “anti-SLAPP statute,” Mass. Gen. Laws ch. 231, 59H. The superior court denied the motion. The Supreme Judicial Court vacated the denial of Defendants’ special motion to dismiss as to the president’s statements to the Boston Globe and otherwise affirmed, holding that a portion of Plaintiffs’ defamation claim was based solely on Defendants’ petitioning activity. Therefore, Defendants satisfied in part their threshold burden under Duracraft. However, because the statute, as construed under current case law, remains at odds with legislative intent and raises constitutional concerns, the court broadened the construction of the statutory term “based on.” The court remanded the matter to the superior court where the burden will shift to Plaintiffs to make a showing adequate to defeat the special motion to dismiss. View "Blanchard v. Steward Carney Hospital, Inc." on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt or to order a new trial. The Court held (1) any error committed by trial counsel during trial did not alter the jury’s verdict, and therefore, Defendant received constitutionally effective assistance of counsel; and (2) testimony elicited from the medical examiner did not violate Defendant’s right of confrontation pursuant to the Sixth Amendment. View "Commonwealth v. Montrond" on Justia Law

Plaintiff, who pleaded guilty to murder in the second degree and was sentenced to life imprisonment with the possibility of parole, filed a petition for parole, which the Parole Board denied. Plaintiff filed a complaint in the nature of certiorari alleging that the board violated the Americans with Disabilities Act and cognate state provisions. The superior court allowed the board’s motion to dismiss. The Supreme Judicial Court reversed, holding (1) the motion judge erred in allowing the board’s motion to dismiss because the board failed first to file the administrative record pursuant to a standing order of the superior court; and (2) contrary to Plaintiff’s assertion, Plaintiff’s commuted life sentence remains a “life sentence” within the meaning of 120 Code Mass. Regs. 301.01(5). The court remanded the case for further development of the record. View "Crowell v. Massachusetts Parole Board" on Justia Law

The Supreme Judicial Court clarified the application of the Florida v. Jardines warrant requirement to a search in a multifamily home. The Court held (1) the side yard of Defendant’s multifamily home in this case was a “constitutionally protected area," and law enforcement’s intrusion into that area to search for a weapon implicated the constitutional warrant requirement; and (2) the superior court properly allowed Defendants’ motions to suppress the loaded sawed-off shotgun found under the porch because the warrantless intrusion here was an unlawful physical intrusion into the curtilage of the residence, therefore violating the warrant requirement of the Fourth Amendment and article 14 of the Massachusetts Declaration of Rights. View "Commonwealth v. Leslie" on Justia Law

A jury found Earl T. Fulgiam and Michael T. Corbin guilty as joint venturers of murder in the first degree of Kevin Thomas, Jr. and Billie Marie Kee. The Supreme Judicial Court affirmed the convictions and declined to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in admitting certain cellular telephone records; (2) the admission of fingerprint cards attributed to Defendants did not violate Defendants’ right to confront witnesses against them; (3) the trial judge did not err in admitting a fingerprint analyst’s testimony related to the fingerprint analysis; and (4) the prosecutor permissibly inferred that a “team” of men committed the murders. View "Commonwealth v. Fulgiam" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on theories of extreme atrocity or cruelty and deliberate premeditation, holding that there was no error in this case warranting reversal, nor was there any reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant’s motion to suppress a statement Defendant made to police; (2) the evidentiary rulings challenged by Defendant were unavailing; (3) there was no prejudicial error in the jury instructions; (4) the trial judge did not abuse his discretion in failing to dismiss several jurors for cause; (5) any potential prejudice to Defendant from the prosecutor’s closing argument was mitigated by a comprehensive limiting instruction; and (6) Defendant’s mandatory sentence of life in prison without the possibility of parole is constitutional. View "Commonwealth v. Colton" on Justia Law

Following a series of disciplinary reprimands and suspensions for misconduct, Plaintiff was removed from her positions as an assistant clerk-magistrate of the Salem Division of the District Court Department. Plaintiff brought this action challenging her removal, arguing that the decision to remove her exceeded the clerk-magistrate’s statutory authority, was arbitrary or capricious, and violated her due process rights. The superior court upheld the removal decision. The Supreme Judicial Court affirmed, holding that it was appropriate for the clerk-magistrate to factor in the whole of Plaintiff’s disciplinary record in terminating her, and therefore, the clerk-magistrate’s decision was not arbitrary or capricious, due process was satisfied, and Plaintiff demonstrated no deviation from the governing statute or rules. View "Perullo v. Advisory Committee on Personnel Standards" on Justia Law

Defendant was charged with offenses arising from alleged domestic violence. The Commonwealth and Defendant filed motions in limine regarding the admissibility of a record of a 911 call placed by the son of Defendant and the alleged victim. Defendant argued that the boy’s statements - including, “my dad just choked my mom” - were not excited utterances and that their admission would violate his right of confrontation right. The judge concluded that the statements were not excited utterances because the boy’s voice on the recording sounded “calm.” A single justice vacated the judge’s order excluding the recording. The Supreme Judicial Court affirmed, holding that the question is not whether the declarant shows “excitement,” but, rather, whether the declarant was acting spontaneously under the influence of the incident at the time the statements were made, and not reflexively. Remanded. View "Commonwealth v. Baldwin" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and armed home invasion. After filing a notice of appeal, Defendant filed a motion for a new trial arguing that his trial counsel was constitutionally ineffective for failing to investigate and present a defense of lack of criminal responsibility. Defendant also filed a second motion for a new trial. The trial court denied Defendant’s two motions for a new trial. The Supreme Judicial Court affirmed Defendant’s convictions and the orders denying the motions for a new trial and declined to reduce the verdict or grant a new trial, holding (1) the trial judge did not err in denying Defendant’s first motion for a new trial, as trial counsel’s decision to forgo further investigation of a lack of criminal responsibility defense based on mental illness was not error; and (2) Defendant’s remaining claims of error were either procedurally waived or without merit. View "Commonwealth v. Holland" on Justia Law

For the first decade of his employment with the Boston police department, Plaintiff was a patrol officer performing the full range of patrol officer duties. The department later placed Plaintiff on administrative duty due to his loss of cognitive function and memory and his “neuropsychological problem of speed and accuracy.” The Boston Patrolmen’s Association subsequently filed a grievance on Plaintiff’s behalf demanding that he be permitted to resume the duties of a patrol officer. An arbitrator found that the Department did not act unreasonably in placing Plaintiff on administrative duty. Plaintiff filed a discrimination lawsuit against the city. The motion judge allowed the city’s motion for summary judgment. The Supreme Judicial Court reversed, holding that summary judgment was not appropriate because there were facts in dispute as to whether Plaintiff was a qualified handicapped person capable of performing the full duties of a patrol officer without posing an unacceptably significant risk of serious injury to himself or others. View "Gannon v. City of Boston" on Justia Law